Harris v. Colvin

Northern District of California, cand-4:2015-cv-01312

STIPULATION AND ORDER FOR SECOND EXTENSION OF TIME [*AS MODIFIED BY THE COURT*]. Signed by Judge Yvonne Gonzalez Rogers on 2/22/16.

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1 BRIAN STRETCH, CSBN 163973 Acting United States Attorney 2 DEBORAH LEE STACHEL, ISBN 230138 Acting Regional Chief Counsel, Region IX 3 Social Security Administration JACOB M. MIKOW, CSBN 238045 4 Special Assistant United States Attorney 5 Social Security Administration 160 Spear St., Suite 800 6 San Francisco, CA 94105 Telephone: (415) 977-8976 7 Facsimile: (415) 744-0134 8 Email: Jacob.Mikow@ssa.gov Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12) REGINA L. HARRIS,) CIVIL NO. 4:15-CV-01312-YGR 13) Plaintiff,) 14) STIPULATION AND PROPOSED vs.) ORDER FOR SECOND EXTENSION 15)) OF TIME FOR DEFENDANT TO FILE CAROLYN W. COLVIN, CROSS-MOTION FOR SUMMARY 16) Acting Commissioner of Social Security,) JUDGMENT AND OPPOSITION TO 17) PLAINTIFF'S MOTION FOR Defendant.) SUMMARY JUDGMENT 18)) 19) *AS MODIFIED BY THE COURT* 20 21 IT IS HEREBY STIPULATED, by and between the parties, that Defendant shall have an extension 22 of time of 30 days to file a Cross-Motion for Summary Judgment and Opposition to Plaintiff's Motion 23 for Summary Judgment. This is Defendant's second request for an extension of time to respond to 24 Plaintiff's motion. Assistant Regional Counsel In Seon Jeong was assigned to this case and has 25 diligently attempted to complete Defendant's responsive brief in a timely matter. However, the 26 undersigned counsel for Defendant seeks this extension due to the press of workload including a high 27 28 Stip. & Prop. Order for Extension, 4:15-CV-01312-YGR 1 volume of other disability matters. Counsel apologizes to the Court for any inconvenience caused by 2 this delay. 3 The new due date for Defendant's Cross-Motion and Opposition will be March 19, 2016. The 4 parties further stipulate that the Court's Scheduling Order shall be modified accordingly. 5 6 7 Respectfully submitted, 8 9 Dated: February 17, 2016 By: /s/ Donald H. Medearis 10 DONALD H. MEDEARIS (as authorized via-email on February 17, 2016) 11 12 MELINDA L. HAAG BRIAN STRETCH United States Attorney 13 Dated: February 17, 2016 By: /s/ Jacob M. Mikow 14 JACOB M. MIKOW 15 Special Assistant United States Attorney Attorneys for Defendant 16 Of Counsel: 17 18 IN SEON JEONG Assistant Regional Counsel 19 20 ORDER 21 22 PURSUANT TO STIPULATION, IT IS SO ORDERED. However, as this is the second request for workload related issues, no further extensions will be granted absent extraordinary circumstances. 23 Counsel is instructed to amend his template to reflect the current United States Attorney. 24 25 February 22, 2016 DATED:________________________ _________________________________ 26 HON. YVONNE GONZALEZ ROGERS UNITED STATE DISTRICT COURT JUDGE 27 28 Stip. & Prop. Order for Extension, 4:15-CV-01312-YGR -2-